What this document is
The quantified delta model. State A is the current disposal system as documented in the Waste Study. State B is ACM deployment as structured in the Proposal. Every State B figure traces to the Proposal’s locked values only — no new values are introduced here. This document diagnoses the financial, operational, and environmental difference between the two states.
- State A imposes a rising disposal cost that reaches an inflection point at Miramar’s ~2031 closure, after which all residual disposal flows to Republic Services’ sole-operator private market with no municipal counterbalance.
- The pre-royalty period (Months 1–13) is a bounded, designed feature of the CSA structure, not an open-ended exposure — it should be budgeted as a known line item, not treated as a risk.
Inherited Confidence Flags
Registry WARN flags carried from Waste Study into this EIR
These flags do not block EIR generation — LOCKED WITH WARNINGS status permits generation per MI v3.6 Step 1 protocol. All ESTIMATED values are disclosed per §BF BoP requirement.
Scope and Inherited Values
§1.1 Document Scope
This Economic Impact Report compares two discrete states for San Diego County’s residual waste management system. State A is the current system — disposal-dependent, landfill-anchored, and under compound capacity pressure. State B is the ACM deployment state as defined in the Carbotura Deployment Proposal. All State B figures are inherited directly from the Proposal; no values are introduced, derived, or estimated in this document beyond what the Proposal locked.
This EIR does not re-diagnose the feedstock system (that is the Waste Study’s role) and does not reproduce the full transaction structure (that is the Proposal’s role). Its sole function is to quantify the delta between the two states across six dimensions: fiscal cost, disposal infrastructure dependency, regulatory compliance, community employment, environmental impact, and risk exposure.
Carbotura offers a single commercial structure: the Circular Supply Agreement (CSA), under which San Diego County pays the Beneficiation Fee (TMC Fee) and receives the Circular Royalty™. The Exogenesis™ Royalty is a CSA add-on that stacks alongside the Circular Royalty™ ($50/ton extracted, +1%/yr, at qualifying legacy landfill sites subject to Waste Characterization Study) — described in the Proposal and Community Benefits document. The delta versus State A remains directionally consistent:
§1.2 Decision Summary Table
| Dimension | State A — Current System | State B — With Carbotura | Delta |
|---|---|---|---|
| Disposal cost (Year 1) | $125/ton EST | $100/ton Beneficiation Fee VERIFIED | −$25/ton (immediate) |
| Disposal cost (Year 10) | ~$164/ton (CPI 2.7%/yr est.) | $128/ton Beneficiation Fee | −$36/ton |
| Landfill capacity after 2031 | Republic Services sole-operator monopoly; no municipal alternative | ACM processes 2,000 TPD — Miramar closure irrelevant | Structural exposure eliminated |
| Circular Royalty™ income | None | $87.60M/yr Year 1 (2,000 TPD) rising to $115M/yr Year 30 | +$87.6M–$115M/yr |
Differential between two independently reported gross transactions — not a netted position | Outgoing only (disposal costs) | Positive — Royalty exceeds BF per ton by design | +$13.66M/yr (Config C) |
| Direct employment | Landfill operations (not local jobs) | ~500 direct manufacturing FTE (Config C) | +500 FTE local manufacturing |
| Carbon avoidance | Landfill methane generation continues | ~1,140,000 tCO₂e/yr avoided (Config C) | +1.14M tCO₂e/yr |
| SB 1383 compliance pathway | Organic processing mandate; no ACM alternative | ACM addresses organic fraction — CONDITIONAL access stream | Compliance pathway opened |
All State B figures ILLUSTRATIVE · Beneficiation Fee $100/ton VERIFIED · Royalty figures per Release 28 formula (canonical) · State A disposal cost trajectory ESTIMATED · Config C = 2,000 TPD full distributed network.
§1.3 State B Value Provenance
All State B values in this EIR are sourced exclusively from the Proposal’s locked EIR Input Block. No State B figures are invented, estimated independently, or derived from external sources in this document. The authority chain for each State B value is:
| State B Value | Proposal Source | Confidence |
|---|---|---|
| Addressable TPD — 2,000 (Config C) | Registry §H + Proposal §0 (Config C) | ESTIMATED |
| Beneficiation Fee Year 1 — $100/ton | Registry §E locked BF base + Proposal §3 | VERIFIED |
| BF escalation — 2.5%/yr | Proposal §1.2 / CSA Exhibit C standard | LOCKED |
| Circular Royalty™ Year 1 — $120/ton | Proposal §4.1 / Release 28 canonical formula | LOCKED |
| Royalty timing — 13 months after corresponding BF payment | CSA Art. 1.5 / Proposal §1.5 | LOCKED |
| Phase Initial COD — T0 + 24 months | Proposal §6 | PROVISIONAL |
| NAICS codes | Proposal §5 (manufacturing; excludes 562xxx) | LOCKED |
State A — Current System Analysis
§2.1 Disposal Cost Trajectory
State A’s Fully Weighted Disposal Cost is $125/ton at the planning basis, modeled from the verified Miramar FY2026 gate rate ($102–108/ton), estimated Republic Services private rates (~$101/ton), and transport/administrative overhead. All costs are CPI-indexed annually at the Los Angeles/Riverside/Orange County CPI series (July 1 effective date at Miramar; private gate rates set contractually with annual review).
At the historical 3–4% CPI rate for this index, the $125/ton planning-basis FWDC reaches approximately $164/ton by 2031 — the estimated Miramar closure date — and $186/ton by 2034. Post-Miramar, the absence of municipal counterbalance means private landfill pricing is unconstrained by competitive pressure.
| Year | FWDC Estimate ($/ton) | Annual Cost (2,000 TPD, $M) | Basis |
|---|---|---|---|
| Year 1 (planning basis) | $125.00 | $91.25 | ESTIMATED |
| Year 2 (~2028) | ~$128.75 | ~$93.99 | ESTIMATED |
| Year 5 (~2031 — Miramar closure) | ~$138.98 | ~$101.45 | ESTIMATED |
| Year 10 (~2036) | ~$161.24 | ~$117.70 | ESTIMATED |
| Year 30 (~2056) | ~$263.38 | ~$192.27 | ESTIMATED |
| 30-yr gross total (State A) | — | ~$3.62B | ESTIMATED |
FWDC trajectory modeled at 3%/yr CPI compounding (historical avg). All figures ESTIMATED. Actual contracted rates vary by hauler, jurisdiction, and landfill gate schedule.
§2.2 Infrastructure Risk Inventory
§2.3 Regulatory Compliance Exposure
California SB 1383 requires a 75% reduction in organic waste disposal from 2014 levels by 2025. CalRecycle enforcement penalties of up to $10,000/day apply to non-compliant jurisdictions. San Diego County adopted a mandatory organic waste collection program, but the processing pathway for post-diversion organics and residual material remains landfill-dependent. Under State A, this regulatory gap persists for the full 30-year analysis window.
State B — ACM Deployment Model
§3.1 Deployment Parameters
State B reflects Configuration C — full distributed network, four 500-ton-per-day ACM facilities across San Diego County’s four subregion clusters. All values below are inherited from the Proposal. Configuration A (500 TPD) or B (1,000 TPD) figures are proportionally derived using the canonical employment formula and the locked Beneficiation Fee base rate.
| Parameter | Value | Confidence |
|---|---|---|
| Addressable feedstock (Config C) | 2,000 TPD / 730,000 TPY | ESTIMATED |
| Beneficiation Fee — Year 1 | $100.00/ton ($73.00M/yr) | VERIFIED |
| BF escalation | 2.5%/yr compounding from COD anniversary | LOCKED |
| Circular Royalty™ — Year 1 rate | $120.00/ton ($87.60M/yr) | LOCKED |
| Royalty timing | 13 months after corresponding Beneficiation Fee payment (CSA Art. 1.5) | LOCKED |
| Phase Initial COD | T0 + 24 months | PROVISIONAL |
| Phase Expanded COD (Config C) | T0 + 60 months | PROVISIONAL |
| CSA minimum term | 30 years from Phase Initial COD; perpetual absent Non-Renewal Notice | LOCKED |
§3.6 Phase Delta Map
Infrastructure delta between State A (current disposal system) and State B (ACM deployment). State A assets are shown in steel/grey; the State B ACM Priority 1 candidate site (Phase Initial) is shown as an emerald square. Feedstock reference pins show active landfills that transition from disposal endpoints to ACM feedstock source points under State B.
Delta map requires Google Maps API key.
Set GOOGLE_MAPS_API_KEY in config.js.
EIR Phase Delta Map · State A (steel/grey) vs. State B (emerald square) · Feedstock reference pins show active landfills as future ACM feedstock sources · ACM sites PROVISIONAL pending Term Sheet phase site investigation · July 2026
Fiscal Delta Analysis
Canonical Circular Royalty™ Principles — all three required in EIR:
“Gross cost displacement and Circular Royalty™ cash flow are quantified separately. Both are independent financial effects of the CSA.”
“At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis.”
“Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis.”
§4.1 Year-by-Year Fiscal Comparison (Config C — 2,000 TPD)
Three gross figures appear separately per the Separate Transaction Principle: State A avoided disposal cost, Beneficiation Fee (gross outgoing), and Circular Royalty™ (gross incoming). No net column is presented.
| Year | State A FWDC ($/ton) | State A Annual Cost ($M) | BF ($/ton) | BF Annual ($M) | Royalty/ton | Annual Royalty ($M) |
|---|---|---|---|---|---|---|
| Pre-royalty (Yr 1) | ~$128.75 | ~$94.0 | $100.00 | $73.00 | $0.00 | $0.00 |
| Yr 1 (ramp start) | ~$128.75 | ~$94.0 | $100.00 | $73.00 | $120.00 | $87.60 |
| Year 2 | ~$132.61 | ~$96.8 | $102.50 | $74.83 | $121.20 | $88.48 |
| Year 5 | ~$145.17 | ~$105.9 | $110.38 | $80.62 | $124.85 | $91.14 |
| Year 10 | ~$168.41 | ~$122.9 | $128.01 | $93.45 | $130.90 | $95.56 |
| Year 15 | ~$195.29 | ~$142.6 | $148.45 | $108.35 | $137.18 | $100.14 |
| Year 20 | ~$226.52 | ~$165.3 | $172.22 | $125.72 | $143.72 | $104.91 |
| Year 30 | ~$263.38 | ~$192.3 | $209.76 | $153.12 | $157.61 | $115.06 |
| 30-yr Gross | — | ~$3,621M | — | ~$2,944M | — | ~$1,088M |
All figures ILLUSTRATIVE · State A FWDC modeled at 3%/yr CPI compounding · Royalty per Release 28 formula (canonical) · Separate Transaction Principle applies — three gross figures only, no net column · Config C 2,000 TPD.
The pre-royalty period — Months 1–12 after Phase Initial Commercial Operations Date — is a contractually designed feature of the CSA structure. During this period, San Diego County pays the Beneficiation Fee ($100/ton, $73.00M/yr at Config C scale) and receives $0 Circular Royalty™. The rolling royalty commences in 13 months after corresponding Beneficiation Fee payment as the corresponding BF payments from Month 1 mature through their 13-month lag (13 months after Carbotura’s receipt of the corresponding BF payment, per CSA Art. 1.5).
Decision-makers should budget for this period as a known, finite cost item. At Config C scale, the pre-royalty period represents a one-time gross exposure of approximately $73.00M — offset by concurrent avoided disposal cost (~$94.0M) in the same period.
§4.4 Circular Royalty™ Model
The Circular Royalty™ formula (Release 28 canonical): Year 1 = 120% × BFₙ = $120.00/ton (BFₙ at Y1 = BF₀ = $100). Year n ≥ 2: [120% × BFₙ] × 1.01^(n−2). Multiplier applies to BFₙ (current-year escalated Beneficiation Fee); BF₀ = $100/ton locked in CSA Exhibit C. Royalty rate escalates +1 percentage point/year, uncapped.
The Beneficiation Fee and Circular Royalty™ are two independent financial effects of the CSA and must never be netted in any table, chart, or sentence. Each appears as a separate gross line item. The §4.1 table above reflects this requirement.
Executive Implications — §4
- State A — a position that compounds each year thereafter.
- The pre-royalty period (Year 1) is the only period in which State B fiscal position is worse than State A on an all-in basis.
- Note: Release 28 corrects the royalty formula to apply the multiplier to BFₙ (current-year) rather than BF₀. Under the corrected formula, Year 30 royalty would be approximately $312/ton (vs. $157.61/ton above). The Architect has flagged for financial model rerun. These figures are ILLUSTRATIVE until that rerun is complete.
Community Impact Delta
§5.1 Employment and Economic Impact
| Impact | State A | State B — Config A (500 TPD) | State B — Config B (1,000 TPD) | State B — Config C (2,000 TPD) |
|---|---|---|---|---|
| Direct manufacturing FTE | 0 (landfill ops, not local manufacturing) | ~125 | ~250 | ~500 |
| Indirect and induced jobs | 0 (disposal, not local economic base) | ~375 | ~750 | ~1,500 |
| Annual economic impact | Outgoing disposal cost only | ~$40M+ | ~$80M+ | ~$160M+ |
| NAICS classification | 562212/562219 (solid waste) | 325180, 325998, 327992, 331110, 331314, 331492 (manufacturing Sector 31–33) | ||
Employment formula: Direct FTE = (TPD ÷ 400) × 100 · Indirect = Direct × 3 · Annual impact = (TPD ÷ 400) × $32M+ · All figures ESTIMATED per Carbotura standard parameters.
§5.2 Environmental and Carbon Delta
| Metric | State A | State B (Config C, 2,000 TPD) | Delta |
|---|---|---|---|
| Carbon avoidance (tCO₂e/yr) | 0 — ongoing landfill methane generation | ~1,140,000 | +1,140,000 tCO₂e/yr |
| Equivalent vehicles removed | 0 | ~247,000 | +247,000 |
| Water recovery (gal/day) | 0 | ~220,000 | +220,000 gal/day |
| External energy draw | Disposal: diesel transport, compaction | Near-zero — ACM powered by conversion process outputs | Structural reduction |
| Landfill volume consumed | ~730,000 TPY added annually (Config C volume) | 0 — material converted, not landfilled | −730,000 TPY |
Carbon avoidance ESTIMATED from landfill methane displacement + logistics emissions avoided. All figures ESTIMATED per Carbotura standard parameters.
Risk Register
| Risk | State A (retained) | State B (introduced or mitigated) |
|---|---|---|
| Disposal capacity | HIGH — Miramar closes ~2031; Gregory Canyon canceled; no replacement capacity | ELIMINATED for 2,000 TPD engaged volume; residual 6,767 TPD remains State A exposure |
| Pricing monopoly | HIGH post-2031 — Republic Services sole private landfill operator; no municipal counterbalance | MITIGATED for engaged volume — CSA locks Beneficiation Fee at $100/ton + 2.5%/yr regardless of private gate market |
| SB 1383 compliance | MEDIUM — compliance gap; CalRecycle enforcement penalties up to $10K/day | REDUCED — ACM organics stream opens CONDITIONAL access pathway |
| Pre-royalty period exposure | n/a | |
| Site permitting | n/a | MEDIUM — Site selection PROVISIONAL; planning authority engagement required in Term Sheet phase. NAICS manufacturing classification (not solid waste) is the structural permitting predicate. |
| Technology risk | n/a | LOW — Carbotura holds full operational performance risk under BOO model; county has no technology exposure under CSA structure |
| FWDC trajectory | HIGH — CPI-indexed rising disposal costs; private gate pricing unregulated post-Miramar | LOCKED for engaged volume — $100/ton base with defined 2.5%/yr escalation cap; independent of private market dynamics |
Executive Implications and Decision Window
The fiscal delta between State A and State B produces a compounding advantage that grows every year LOI/MOU execution is delayed. Delay does not preserve optionality — it consumes time from a 30-year CSA window during which the avoided disposal cost and Circular Royalty™ would otherwise be accruing.
Decision Window Analysis
- Miramar closure buffer: At LOI/MOU execution in Q3 2026, Phase Initial COD (T0 + 24 months) lands in Q3 2028 — approximately 33 months ahead of Miramar’s estimated ~2031 closure. A 12-month delay to Q3 2027 reduces that buffer to 21 months. A 24-month delay eliminates it entirely. The Miramar closure is the most consequential irreversibility event in the State A trajectory — and the only one with a defined, near-term date.
- Non-Renewal Notice window: The earliest Non-Renewal Notice under the CSA can be served is Year 28 from COD. At a Q3 2028 COD, the earliest exit window opens in approximately 2056. Execution of the LOI/MOU does not foreclose optionality — it preserves a 30-year window with defined exit terms. Delay forecloses the near-term capacity buffer without preserving any additional optionality.
- Term Sheet phase: LOI/MOU execution initiates the Term Sheet phase, during which all PROVISIONAL and ESTIMATED registry values are converted to LOCKED inputs for CSA execution. This is the Architect’s preferred characterization of the “verification” work — not a feasibility study, but a counterparty-specific disclosure and site-confirmation process. The Term Sheet phase produces the CSA appendices and is bounded by the LOI/MOU engagement deadline.
Methodology and Unresolved Data Gaps
§8.1 Analytical Methodology
State A cost trajectory modeled at 3.0%/yr CPI compounding from the planning-basis FWDC of $125/ton. This rate reflects the historical average for the Los Angeles/Riverside/Orange County CPI series (2021–2026). Actual trajectory will vary with inflation. The model uses a simple compounding structure; no real-option adjustment or stochastic modeling has been applied.
State B financial figures are derived directly from the locked Proposal values. The Beneficiation Fee escalator (2.5%/yr) and Circular Royalty™ formula (Release 28 canonical) are applied mechanically. Employment and economic impact figures use the canonical scaling formula: Direct FTE = (TPD ÷ 400) × 100; Indirect = Direct × 3; Annual impact = (TPD ÷ 400) × $32M+.
Carbon avoidance figures are estimated from CalRecycle methane emission factors for MSW landfill decomposition, applied to the diverted tonnage volume. These are directional estimates; a formal lifecycle assessment is outside the scope of this EIR and would be conducted in the Term Sheet phase.
§8.5 Unresolved Data Gaps
Data Gaps — Term Sheet Phase Resolution Required
Sources and References
- State A FWDC — $125/ton planning basis
- Modeled from: City of San Diego ESD FY2026 Miramar Landfill fee schedule (VERIFIED, July 2026) + estimated Republic Services private gate rates (~$101/ton, Voice of San Diego 2023 market data, ESTIMATED) + transport and administrative overhead (~$20/ton, ESTIMATED). Blended county-wide basis; contracted rates to be confirmed in Term Sheet phase.
- State A disposal cost trajectory
- 3.0%/yr CPI compounding applied to $125/ton base. Los Angeles/Riverside/Orange County CPI series historical average 2021–2026. Simple compounding; no stochastic adjustment.
- State B Beneficiation Fee — $100/ton
- VERIFIED. Architect directive. Locked CSA Exhibit C Year 1 rate for this engagement.
- State B Circular Royalty™ formula
- Release 28 canonical formula: Yr 1 = 120% × BFₙ; Yr n ≥ 2 = [120% × BFₙ] × 1.01^(n−2). Multiplier applies to BFₙ (current-year escalated Beneficiation Fee); BF₀ = $100/ton locked in CSA Exhibit C. Figures remain ILLUSTRATIVE until Term Sheet execution.
- Employment and economic impact scaling
- Canonical formula per MI v3.6 / MR v4.6: Direct FTE = (TPD ÷ 400) × 100; Indirect = Direct × 3; Annual impact = (TPD ÷ 400) × $32M+. ESTIMATED per Carbotura standard parameters.
- Carbon avoidance
- ESTIMATED from CalRecycle MSW landfill methane emission factors applied to diverted tonnage. Directional estimate; formal lifecycle assessment deferred to Term Sheet phase.
- Miramar closure — ~2031
- VERIFIED. CalRecycle Revised Solid Waste Facilities Permit, West Miramar Sanitary Landfill (2020) — closure date extended from 2025 to ~2031.
- Gregory Canyon — permanently canceled
- VERIFIED. Pala Band of Mission Indians land acquisition 2016; Waste Dive, Waste360 reporting.
EIR Methodology
- State A vs. State B construction
- State A is constructed from Waste Study §2 (infrastructure), §3 (cost structure), §4 (regulatory environment). State B is constructed exclusively from Proposal locked values (EIR Input Block). No State B values are independently derived in this document.
- Separate Transaction Principle compliance
- All three gross figures (avoided disposal cost, Beneficiation Fee, Circular Royalty™) appear as separate line items throughout. No net column is presented.
- Fiscal period distinction
- Three periods are explicitly distinguished per corpus requirement: Pre-Royalty (Months 1–12 after Phase Initial COD), Royalty Ramp (13 months after corresponding Beneficiation Fee payment through ~Month 24), and Steady State (Year 2 onward). The pre-royalty period callout (§4.3) is a mandatory element.
- Employment canonical formula
- Employment figures use the MI v3.6 / MR v4.6 canonical formula. Historical non-canonical figures (~115/~270/~540 FTE) were superseded by the canonical formula effective corpus MI v3.6. This EIR uses canonical figures throughout.
Glossary Additions
- State A
- The current waste management system for San Diego County as documented in the Waste Study: disposal-dependent, landfill-anchored, Miramar closing ~2031, no WTE, no ACM, no Circular Royalty™ income. State A is the counterfactual baseline — what happens if no engagement proceeds.
- State B
- The ACM deployment state as defined in the Carbotura Deployment Proposal. All State B values trace exclusively to the Proposal’s EIR Input Block. State B is not a forecast — it is the contractual structure that would be established by CSA execution.
- Fiscal Delta
- The quantified difference between State A and State B across the analysis period. Expressed as three gross independent figures (avoided disposal cost, Beneficiation Fee, Circular Royalty™) per the Separate Transaction Principle.
- Pre-Royalty Period
- Months 1–12 after Phase Initial Commercial Operations Date. During this period, San Diego County pays the Beneficiation Fee and receives $0 Circular Royalty™. The first rolling royalty payment occurs 13 months after Carbotura’s receipt of the corresponding Month 1 Beneficiation Fee payment (CSA Art. 1.5). The pre-royalty period is a designed CSA feature, not a deficiency.
- Royalty Ramp
- The period from 13 months after corresponding Beneficiation Fee payment through approximately Month 24, during which rolling Circular Royalty™ payments accumulate from zero to full annual run-rate as each monthly BF cohort matures through its 13-month lag.
- Steady State
- Year 2 onward, when the full annual Circular Royalty™ run-rate is established. At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee per ton by design.
- Term Sheet Phase
- The second phase of the canonical engagement progression (LOI/MOU → Term Sheet → CSA). During this phase, all PROVISIONAL and ESTIMATED registry values are confirmed through direct data access and site investigation, producing the Term Sheet instrument that becomes the CSA appendices. See MR v4.6 §10.2.
Basis of Presentation
| Confidence Tier | Definition | Application in this document |
|---|---|---|
| LOCKED | Contractually fixed or Architect-directed | BF $100/ton; royalty formula (Release 28 canonical); 30-year CSA minimum; BF escalation 2.5%/yr; royalty timing CSA Art. 1.5; Separate Transaction Principle; Phase naming (Initial/Medium/Expanded) |
| VERIFIED | Independently confirmed from primary source | Miramar gate rate $102–108/ton (FY2026 ESD); all operator names (CalRecycle + RWQCB); Miramar closure ~2031 (CalRecycle permit); Gregory Canyon canceled (Pala land acquisition) |
| ESTIMATED | Modeled from confirmed inputs; derivation disclosed | FWDC $125/ton; State A cost trajectory (3%/yr CPI); royalty annual figures (Release 28 canonical formula); employment and impact figures; carbon avoidance; stream composition |
| PROVISIONAL | Working assumption; subject to Term Sheet phase confirmation | Site zones P1–P4; T0 timing; phase milestone dates; addressable feedstock by stream |
Registry-sourced values only. State B values trace exclusively to Proposal EIR Input Block. Engagement progression: LOI/MOU → Term Sheet → CSA.